Gergely Czoboly -Gabriella Erdős: The Implementation of the Global Minimum Corporate Tax in Hungary

Abstract

The introduction of Pillar 2 resulted in significant changes not only in international taxation but also in the national tax systems. This paper tackles the major decisions points from Hungary's perspective, which is considered a low tax developing country, and for whom the introduction of a QDMTT system is a must. It touches upon some of the difficulties caused by the potential use of different accounting systems, the extended scope of covered taxes, the grandfathering of the already obtained tax incentives through deferred taxes, introduction of new refundable tax incentives, safe harbor status and the uncertainties of the peer review process. It includes remarks on the weaknesses of dispute resolution process, and on the complexities of the implementation of an EU directive with embedded non-binding (recent and future) guidance of OECD into the national legal system.